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Business Taxation
Accounting, ERISA, Ethics, Etc.
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October 21-25, 2019
October 26-30, 2020

SCHEDULES : What's New in the Income Tax World

Cameron N. Cosby, Presiding

7:15 – Registration Desk Opens

8:00-9:00 – Breakfast

9:00-10:30 – Recent Federal Income Tax Developments – This session highlights significant changes affecting taxpayers over the past twelve months, including court decisions, rulings, and statutory and regulatory developments
Bruce A. McGovern, Professor of Law and Director, Tax Clinic, South Texas College of Law Houston, Houston, TX
Cassady V. "Cass" Brewer, Associate Professor of Law, Georgia State University College of Law, Atlanta, GA

10:30-10:45 – Break

10:45-12:00 – Recent Federal Income Tax Developments (con't)

12:15-1:05 – Mid-day Program: What Every Family Business and Family Office Need To Know – On the income tax side, the multi-year repeal of the Section 212 investment expense deduction in the 2017 Tax Cut and Jobs Act compel family offices and businesses to take a harder look at protecting their “trade or business” status under Lender.  On the estate and gift tax side, a long anticipated opinion will shed new light on S-Corp tax affecting and USPAP 9-3 recognition that non-controlling interests get no benefit from non-operating assets.  And perhaps most importantly, that case teaches us how principled families can best preserve their businesses for generations to come.
Sponsored by Chamberlain, Hrdlicka, White, Williams & Aughtry and presented by Allan J. Zachariah, John W. Hackney, David D. Aughtry and Stephanie Brun de Pontet

Jeffery S. Drummonds,

1:15-2:45 – For Select Taxpayers Only: 20% Off Until 2026! New IRC § 199A and “Qualified Business Income” – New §199A allows noncorporate taxpayers a special deduction (subject to limitations) equal to 20% of qualified business income (“QBI”). Essentially, the Tax Cuts and Jobs Act results in a 20% reduction in tax rates until 2026 for those noncorporate taxpayers earning QBI who can structure their operations and report as required to take advantage of new § 199A. This panel explores new § 199A in depth, including the use of LLCs, S corporations, management companies, compensation arrangements, and other strategies to maximize QBI and the benefits of new § 199A.
Adam S. Feuerstein, Principal, PricewaterhouseCoopers LLP, McLean, VA
Sarah Ritchey Haradon, Associate, Holland & Hart LLP, Denver, CO

2:45-4:00 – The Employee vs. Independent Contractor Determination – More Important Than Ever – Properly classifying someone as an independent contractor or employee involves a fact-sensitive analysis that derives from a complicated set of factors.  This determination is more relevant than ever with new § 199A and the 20% deduction for QBI, given that the deduction does not apply to employee compensation but often will apply to compensation paid to an independent contractor. The employee vs. independent contractor determination has long been a focus in IRS audits, and given the increased stakes, it is likely that the pressure associated with this issue will only increase. This session will provide strategies for evaluating independent contractor relationships and avoiding claims of independent contractor misclassification.
Todd H. Lebowitz, Partner, BakerHostetler LLP, Cleveland, OH

4:00-4:15 – Break

4:15-5:30 – State Tax Update, With a Focus on the Implications of TCJA – With TCJA’s dramatic reduction in corporate rates, $10,000 limitation on personal deductions for state and local taxes, and the impact of new § 199A on independent contractor versus employee status, not to mention SCOTUS’s reconsideration of Quill, state and local tax planning is even more critical. This expert panel addresses TCJA’s immediate implications for state and local tax planning, and gazes into the crystal ball of what the future may hold.
James H. Adams, Principal, Ernst & Young LLP, Atlanta, GA
Brian B. McCuller, Shareholder, LBMC, PC, Nashville, TN

5:30-7:00 – Cocktail Party